Validation Master Plan

Validation Master Plan (VMP) for the Pharma Co., Inc. Springfield, NY Facility

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DOCUMENT NO.:
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TITLE: Validation Master Plan (VMP) for the Pharma Co., EFFECTIVE DATE: TRAINING DATE:
Inc. Springfield, NY Facility
SUPERSEDES DATE: PAGE NO.:
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Glossary
2.0 PURPOSE AND INTRODUCTION......................................................................................................3
2.1 INTRODUCTION ......................................................................................................................... 3
2.2 PURPOSE ..................................................................................................................................... 3
3.0 SCOPE.....................................................................................................................................................4
4.0 RESPONSIBILITIES ..............................................................................................................................4
4.1 SITE QUALITY ASSURANCE VALIDATION ......................................................................... 5
4.2 SITE ENGINEERING VALIDATION ........................................................................................ 6
4.3 SITE MANUFACTURING TECHNICAL SUPPORT .............................................................. 6
4.4 SITE MANUFACTURING .......................................................................................................... 7
4.5 SITE ENGINEERING ................................................................................................................. 8
4.6 QUALITY CONTROL ................................................................................................................. 8
4.7 REGULATORY AFFAIRS ......................................................................................................... 9
5.0 DEFINITIONS, ABREVIATIONS AND REFERENCES ...................................................................9
5.1 DEFINITIONS LIST .................................................................................................................... 9
5.2 ABBREVIATION LIST .............................................................................................................. 12
5.3 REFERENCES .......................................................................................................................... 12
6.0 MATERIALS ..........................................................................................................................................12
7.0 PROCEDURE .......................................................................................................................................13
7.1 SPRINGFIELD, NY FACILITY OVERVIEW ......................................................................... 13
7.2 VALIDATION MASTER PLAN GOVERNANCE .................................................................. 13
7.3 VALIDATION APPROACH ...................................................................................................... 15
7.4 VALIDATION PROCEDURES ................................................................................................ 17
7.5 VALIDATION SUPPORT SYSTEMS..................................................................................... 18
7.6 KEY SOPs GOVERNING AND SUPPORTING THE ALLSTON LANDING VALIDATION
PROGRAM ................................................................................................................................ 21
7.7 IDENTIFICATION AND DESCRIPTION OF MANUFACTURING SYSTEMS AND
EQUIPMENT PRESENTLY IN USE AT THE SPRINGFIELD, NY FACILITY AND
ASSOCIATED COMPLETED VALIDATION ........................................................................ 21
7.8 VALIDATION MASTER PLAN REVIEW ............................................................................... 21
8.0 ATTACHMENTS...................................................................................................................................21
8.1 Attachment A: Process Flow Diagrams ................................................................................ 21
8.2 Attachment B: Key SOPs Governing and Supporting the Springfield, NY Facility
Validation Program .................................................................................................................... 21
8.3 Attachment C: Process Equipment List and Associated Validation Protocol Numbers
..................................................................................................................................................... 21
9.0 REVISION HISTORY...........................................................................................................................27
9.1 Revision History Table ............................................................................................................. 27

NOTICE
THIS DOCUMENT IS PROPRIETARY AND ITS CONTENTS ARE THE EXCLUSIVE PROPERTY OF PHARMA CO., INC.

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2.0 PURPOSE AND INTRODUCTION

2.1 INTRODUCTION

The validation program at the Springfield, NY Facility is intended to satisfy current domestic
and international regulations, guidelines and policies for drugs, biologics and APIs to verify
the equipment, systems, utilities, software and processes are properly designed, installed,
and function as intended in a consistent and controlled manner. The validation program
complies with Corporate Quality Standards and Polices (Ref. SOP-XXXX – Validation
Program).

The revision of the Site Validation Master Plan (SVMP) comes from the validation
philosophy changes resulting from the implementation of the “validation lifecycle” approach
at Springfield, NY Facility. The changes made in this revision of the Springfield, NY Facility
SVMP bring the plan into alignment with the new lifecycle approach. The Springfield, NY
Facility has developed the site validation governance document SOP-XXXX, “Validation
Project Life Cycle Approach at the Springfield, NY Facility”, which defines the
validation philosophy to be used for validation at Springfield, NY Facility. SOP-XXXX uses
a risk-based approach with emphasis on verification and qualification that is focused on the
high risk attributes of facilities, utilities, equipment, and processes. This SVMP introduces
use of subordinate VMPs (sub-VMPs) that are categorized into eight areas and address the
full scope of Validation requirements applicable to the Springfield, NY Facility site in
support of SVMP.

2.2 PURPOSE

The purpose of validation is to assure that the facility, manufacturing process, and
supporting services are capable of supporting the manufacture of pharmaceutical product
that consistently meets its predetermined quality attributes. For this reason, each facet of
the Springfield, NY Facility site related to CGMP manufacture, monitoring, storage, and
testing will be validated. The Validation program is integral to design, construction /
fabrication, and CGMP Operation of the facility. Validation testing is intended to proactively
establish CGMP compliance prior to initiating manufacture of commercial product for
distribution. In addition, the sustenance operations at Springfield, NY Facility, such as
quality change control, calibration program, preventive maintenance, and periodic
requalification of critical equipment and processes ensure that manufacturing equipment
and processes stay under the validated state.

The purpose of this SVMP is to:

• Define the requirements and validation approach for validation of systems,
equipment, and processes at Pharma Co., Inc. Corporation’s Springfield, NY Facility.
• To list or reference the documentation supporting the current validated state of the
Springfield, NY Facility.

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This SVMP explains the governance structure in place that will achieve, demonstrate and
maintain acceptable standards of validation for systems, equipment, and processes used in
the manufacture of drug product at the Springfield, NY Facility. If the methodologies and
rationale presented herein are not followed, the rationale behind the alternate approach
must be documented appropriately.

This document is designed to accomplish the following objectives:

• Identify the key Standard Operating Procedures governing and supporting the
validation program presented in SOP-XXXX.
• Describe the manufacturing systems, equipment, and processes presently in use at
the Springfield, NY Facility.
• Itemize the equipment and utilities used in the Springfield, NY Facility manufacturing
systems and link them to completed validation studies as evidence of a validated
state.

3.0 SCOPE

This Site Validation Master Plan applies to all verification, qualification, and validation
activities that support commercial manufacturing at Pharma Co., Inc. Corporation’s
Springfield, NY Facility. This VMP is a high-level document that refers to various
supporting documents. Validation program elements include:

• Validation/qualification of facilities/utilities/equipment and corresponding
automation/controls
• Validation of manufacturing processes
• Cleaning validation
• Sterilization and depyrogenation
• Enterprise Computer systems
• QC Laboratory equipment and methods
• Interval based requalification

The commercial products that are currently manufactured, packaged, or stored at the
Springfield, NY Facility are listed in Table 7.1-1. The equipment within the scope of this
Validation Master Plan are listed in Attachment D, Process Equipment List and Associated
Validation.

4.0 RESPONSIBILITIES

This SVMP will be approved by the heads of the departments (or their designees) listed in
this section.

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The validation activities in Springfield, NY Facility are the responsibility of the Validation,
Engineering, Manufacturing, MTS, and Quality Assurance groups as shown in Figure 1.

The responsibilities outlined below align with the Validation Lifecycle Approach that is
presented in SOP-XXXX.

4.1 SITE QUALITY ASSURANCE VALIDATION
• Generate, review, and maintain approve SVMP
• Review and approve the sub-VMPs and Project VPs
• Assist with the generation of User Requirements (URs) document
• Review and approve the URS document
• Assist with the performance of risk assessments
• Review and approve Risk Assessments documents
• Review and approve Critical Aspects (CAs) list and acceptance criteria, as
applicable
• Review and approve the Process Control Strategy
• Review and approve the Operational Control Strategy
• Review and approve Commissioning and Qualification and Validation Plans
• Review and approve Qualification Protocols and Reports for facilities, utilities,
equipment, and processes that have CAs
• Review and approve Computerized Systems’ Protocols and Reports
• Review and approve Performance Qualification (PQ) Protocols and Reports

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• Review and approve Process Validation (PV) and Continued Verification
Protocols and Reports
• Review and approve Qualification and Validation Protocol Deviations
• Approve the use of vendor documentation to verify functionality of facility, utility,
and equipment
• Reviewing and approving the Site’s Equipment Requalification related
documents

4.2 SITE ENGINEERING VALIDATION
• Review and approve SVMP
• Generate, review, approve, and maintain sub-VMP for Facilities, Equipment
(including QC Lab storage and process equipment, such as refrigerators,
autoclaves and incubators) and Utilities, Cleaning Process, Sterilization and
Depyrogenation Process, and Computerized Systems
• Lead/generate, review and approve Site Project VP for new products or projects
• Maintain Validation Schedule per the Project Execution Plan (PEP) and Project
VP and CCR timelines
• Assist with the generation of URS document
• Review and approve URS document
• Lead/perform risk assessments using CA list
• Review and approve Risk Assessment document
• Generate, review, and approve IQ, OQ, PQ Protocols and Reports for facilities,
utilities, equipment, and processes
• Generate, review, and approve PQ Protocols and Reports
• Generate, review, and approve Protocol Deviations
• Review and approve Computer Systems’ Protocols and Reports

4.3 SITE MANUFACTURING TECHNICAL SUPPORT
• Review and approve the SVMP, sub-VMPs, and Project VPs, as appropriate
• Generate, review, approve, and maintain sub-VMP or PV
• Review and approve URS of document
• Review and approve Risk Assessment document, as applicable
• Review and approve Validation Plans, as applicable
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• Review approve and assist in updating the Process Control Strategy
• Generate, review, and approve the Operational Control Strategy
• Lead /perform Technical Transfer activities for product transfer
• Lead/perform process development / engineering runs
• Lead. generate, review, and approve PV and Continued Verification Protocols
and Reports
• Execute PV Protocols
• Generate, review, and approve PV Protocol Deviations
• Create and update Manufacturing Process Descriptions and associated
Manufacturing Flow Diagrams (MFDs)
• Generate process related sections of the Project VPs
• Review and approve Project VPs that include PV
• Lead/perform risk assessments for PV
• Create and update Manufacturing History File (MHF)

4.4 SITE MANUFACTURING
• Assist with the generation of the SVMP, sub-VMPs, and Project VPs, as
applicable
• Review and approve the SVMP, sub-VMPs, and Project VPs, as applicable
• Review and approve the Process Control Strategy
• Assist Site Engineering with generation of project schedule
• Generate manufacturing SOPs for use during validation
• Review and approve IQ, OQ, PQ, PV, and Continued Verification Protocols and
Reports for facilities, utilities, equipment, and processes as applicable
• Prepare schedule in support of IQ, OQ, PQ, PV, and Continued Verification
Protocols execution
• Ensure equipment/facilities/materials/personnel availability and technical support
on the operation of the equipment during execution of qualification and validation
activities
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• Ensure manufacturing procedures are developed for maintaining the validated
equipment in its validated state throughout its lifecycle
• Review and approve Protocol Deviations affecting process equipment
• Manage and execute the Site’s Equipment Requalification program

4.5 SITE ENGINEERING
• Lead the generation of URS document
• Generate Functional Specifications based on URS
applicable
• Review and approve the SVMP, sub-VMPs, and Project VPs, as applicable
• Generate, review, approve, and maintain sub-VMP for Computer Systems
• Generate, review, and approve Computer Systems Protocols and Reports
• Review and approve Verification (including IQ and OQ) and PQ Protocols and
Reports for facilities, utilities, equipment, and processes as applicable
• Participate in execution of Verification Protocols, as necessary
• Review and approve Protocol Deviations affecting facilities, utilities, and
Computer Systems
• Review and approve the Site’s Equipment Requalification documents related to
facilities and utilities

4.6 QUALITY CONTROL
applicable
• Review and approve the SVMP and sub-VMPs, as applicable
• Generate, review, approve, manage execution of, and maintain sub-VMPs for
QC Laboratories
• Review and approve Site Project VP for new products when QC testing is
required
• Receive and use transferred validated methods
• Review and approve method validation protocols and reports
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• Generate, review and approve validation protocols and reports for laboratory test
instrumentation
• Review and approve laboratory equipment validation protocols and reports
storage and process equipment, such as refrigerators, autoclaves and incubators
• Review the PQ and PV protocols for analytical and microbiological testing
requirements, as applicable
• Perform testing required for validation samples, as applicable
• Review the PQ and PV Final Reports and verify the accuracy of testing data, as
applicable
• Review and approve Protocol Deviations affecting QC test results and equipment

4.7 REGULATORY AFFAIRS
• Assist with the review of SVMP, sub-VMPs, and validation requirements to
ensure compliance with regulatory filings
• Update regulatory filings as necessary based on approved validation data
• Assess the impact of validation activities on current approved product filings
• Provide filing dates as part of validation activity scheduling
• Incorporate pertinent validation data into annual reports

5.0 DEFINITIONS, ABREVIATIONS AND REFERENCES

5.1 DEFINITIONS LIST

Cleaning Documented evidence that a cleaning process is consistently and
Validation (CV)effectively reducing potential product and/or cleaning agent residues to
pre-determined acceptable limits.
Cleaning Documented evidence that equipment is cleaned to pre-determined
Verification specifications and may be released for use.
Clean in Place Introduction of cleaning solution and/or water rinses into equipment that
(CIP) is fixed in place, for purposes of removing potential product and/or
cleaning agent residues.
Clean out of Cleaning of portable or disassembled equipment/parts involving the use
Place (COP) of a cleaning station in a remote designated location.
Commissioning A well-planned, documented, and managed engineering approach to
the startup and turnover of facilities, systems, and equipment to the
System Owner that results in a safe and functional environment that
meets established design requirements and stakeholder expectations.
Concurrent Validation of equipment, systems or processes while the equipment,
Validation system or process is in current use for clinical or commercial production.
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Critical Elements of the systems or equipment, which are critical to the product
Aspects (CA) quality.
Critical ProcessA process parameter whose variability has an impact on a critical quality
Parameter attribute and therefore should be monitored or controlled to ensure the
(CPP) process produces the desired quality (ICH Q8 (R2)).
Critical QualityA physical, chemical, biological or microbiological property or
Attribute (CQA) characteristic that should be within an appropriate limit, range, or
distribution to ensure the desired product quality (ICH Q8 (R2)).
Design Review A formal, documented, comprehensive and systematic examination of
the technical aspects of a product design or process. (21CFR Part
820.30)
Direct Impact Utility that is used for manufacturing of the product or critical processes
Utility (CIP, SIP) such as Water for Injection, Clean Steam, and Process
Gases
Family A Performance Qualification approach that allows for a reduced number
Approach of validation studies when using equipment of equivalent design,
manufacture and operational functionality. This approach is typically
used for PQ for Bioreactors and Vessels
Functional A prospective document that builds on the User Requirement
Requirement Specification (URS) and provides a basic narrative on what functions
Specification the process and its control system are expected to perform.
Installation Establishing documented evidence that the equipment, system or
Qualification software received is correct, is installed properly, in accordance with
(IQ) Pharma Co., Inc.’s and the manufacturer’s requirements, and has the
proper documentation and support information.
Matrix approach A validation approach that uses a philosophy which allows for the
testing of a subset of product batches or “model / placebo products to
validate the entire range of a product /batch, in lieu of testing each
product / batch in the matrix. Typical examples of appropriate
applications of this approach include mixing validation and pooling
validation. The bracketing selection is based upon product / batch
attributes such as concentration, solubility, ingredient types, and batch
size.
Operational Establishing documented evidence that the equipment, system or
Qualification software installed, functions in accordance with Pharma Co., Inc.’s and
(OQ) the manufacturer’s requirements over the intended range of use, or for
the intended applications.
Performance Establishing documented evidence that equipment or systems perform
Qualification in a controlled and reproducible manner in accordance with Pharma
(PQ) Co., Inc.’s requirements under specific operational parameters, either at
the allowable upper and lower limits of the operation or using worse
case conditions compared to intended operating ranges.
Process The collection and evaluation of data, from the process design stage
Validation (PV) through commercial production, which establishes scientific evidence
that a process is capable of consistently delivering quality products.
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(Guidance for Industry – Process Validation: General Principles and
Practices, FDA, January 2011, Rev 1).
Project A prospective document that defines the scope, requirements, rationale
Validation Plan and protocols necessary for the validation of a new project or process in
an existing site, which is under validated state.
Prospective Validation of equipment, systems or processes prior to the
Validation release/approval of the equipment, system or process for commercial
production or commercial distribution of product.
Protocol A prospective or concurrent test plan with pre-established acceptance
criteria that when executed is intended to produce documented
evidence that a system or system component has been properly tested.
Quality Attribute A physical, chemical, or microbiological property of characteristic of a
material that directly or indirectly impacts quality.
Re-Qualification Establishing documented evidence that existing equipment and
(Periodic processes continue to operate in a validated state, demonstrating
Qualification) continued compliance, effective and reproducibility. This protocol type is
utilized for time based re-qualification activities, such as autoclaves,
SIP, ovens, SIP ovens, lyophilizers, environmental rooms, and cleaning
and is not applicable to Change Control Request driven validation.
Re-Validation The validation of a previously validated process typically necessitated
by a change modification to the process.
Risk Based An approach that allows basing the project related activities on risk
Approach analysis and placing extra effort on activities that are assessed as
posing a higher risk to the processes and product quality.
User A prospective document that describes what the equipment or system is
Requirement supposed to do, thus containing at least a set of criteria or conditions
Specification that have to be met. This can include regulatory, corporate, and process
(URS) requirements.
Validation Documented evidence, which provides a high degree of assurance that
a specific process will consistently meet its pre-determined
specifications and quality attributes.
Validation A prospective document that defines the scope, requirements, rationale,
Master Plan and protocols necessary for the validation of a new project or process.
Validation A prospective document that provides a detailed test plan used to
Protocol qualify/validate equipment, systems, utilities, software or processes.
Validation A document that provides a detailed summary of the results from the
Protocol Final execution of a Validation Protocol.
Report

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5.2 ABBREVIATION LIST

API Active Pharmaceutical Ingredient
ASME American Society of Mechanical Engineers
CFR Code of Federal Regulations
cGMP current Good Manufacturing Practices
CIP Clean-In-Place
CPP Critical Process Parameters
CQA Critical Quality Attributes
CA Critical Aspects
EMA European Medicines Agency
FDA Food and Drug Administration
GAMP Good Automated Manufacturing Practices
ICH International Conference on Harmonization
IQ Installation Qualification
ISO International Standards Organization
ISPE International Society of Pharmaceutical Engineers
KPP Key Process Parameter
MFD Manufacturing Flow Diagram
OQ Operational Qualification
PEP Project Execution Plan
PQ Performance Qualification
PV Process Validation
QA Quality Assurance
QC Quality Control
RQ Re-Qualification
SIP Steam-In-Place
SME Subject Matter Expert
SOP Standard Operating Procedure
SVMP Site Validation Master Plan
UR User Requirement
VMP Validation Master Plan

5.3 REFERENCES
• See Attachment B for Key regulatory references and Corporate and site SOPs
Governing and Supporting the Springfield, NY Facility Validation Program.

6.0 MATERIALS

All materials needed to perform the functions referenced in this document will be found in
the individual referenced documents.

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7.0 PROCEDURE

7.1 SPRINGFIELD, NY FACILITY OVERVIEW

The Pharma Co., Inc., and is located at: 1 Main Street, Springfield, NY.
Pharma Co., Inc.’s Springfield, NY facility is a multi-product manufacturing facility for
xxxx products. Manufacturing operations performed at the Springfield, NY facility
include bulk drug substance activities, testing, labeling, and packaging.
Drug substance manufacture for Product A is performed at this facility (see
Attachment A for Process Flow Diagram.)
Packaging and labeling operations are performed at this facility for Product A.
Quality Control (QC) testing for Product A may be performed in qualified laboratories
at Springfield, NY Facility, and approved vendor sites.
Table 7.1-1 outlines the manufacturing activities performed at the Springfield, NY
Facility for each product.

Table 7.1-1: Manufacturing Activities Performed at Springfield by Product
Product Activities Performed at Springfield, NY Facility
Product A Manufacturing, formulation, testing, labeling, and packaging

7.2 VALIDATION MASTER PLAN GOVERNANCE

The Validation Program incorporates evaluation and testing to establish:
• Manufacturing & Laboratory Facility Installation
• Direct Impact Utility Installation, Operation, & Performance
• Manufacturing Equipment Installation, Operation, & Performance
• Validation of Computer Systems & Software
• Validation of Manufacturing Equipment Cleaning Processes and Cycles
• Qualification of Laboratory Equipment and Instruments
• Validation of Analytical, Physical, & Microbiological Test Methods
• Transfer / Development of Manufacturing Processes
• Qualification of Environmental Controls and Clean Rooms
• Validation of Manufacturing Processes
• Assessment and pre-determination of the longevity of CGMP equipment

It is not intended that the SVMP will describe the requirements in detail for execution of the
various Validation Program elements. The detailed requirement description may be found
in sub-VMPs, Standard Operating Procedures, Corporate Level Standards or Practices, or
relevant protocols.

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This SVMP will be revised at a minimum once per year to reflect the changes made to the
validated facilities, utilities, equipment, and processes at Springfield, NY Facility. In
addition, a periodic SVMP Summary Report (issued annually, at minimum) will document
the summary of changes to the validated systems and corresponding validation documents.
The Process Equipment List and associated document numbers will be updated with the
new document numbers and titles.

In order to address the full scope of Validation requirements applicable to the Springfield,
NY Facility site, validation activities have been categorized into eight areas, which will be
executed by corresponding sub-VMPs, to be created, and as listed below:

• Sterilization and Depyrogenation Master Plan for Springfield, NY Facility
• Cleaning Validation Master Plan for Springfield, NY Facility
• Process Validation Master Plan for Springfield, NY Facility
• Facility, Equipment, and Utility Validation Master Plan for Springfield, NY
Facility
• Computer System Validation Master Plan for Springfield, NY Facility
• Requalification Validation Master Plan for Springfield, NY Facility
• QC Laboratory Equipment and Instrumentation Qualification Master Plan for
Springfield, NY Facility
• Test Method Validation Master Plan for Springfield, NY Facility

The eight sub-VMPs will supplement the overarching SVMP, and will be governed by
corresponding Corporate Quality Operations Standards. The Sub-VMPs will present the
specific validation requirements and projects within each of these validation groupings,
along with the necessary details on the scope, validation approach, roles and
responsibilities, required deliverables (equipment, systems, processes to be validated and
corresponding protocols and documentation, URS, SOPs, test methods, etc.), and
acceptance criteria. The projected schedule and required resources will be covered by the
Project Execution Plan (PEP) and Project VP.

Standard content of the Sub-VMPs will include:
• Policy statement and description of Validation Methodology to be followed.
• Listing of applicable governance policy and procedures describing program
requirements.
• Listing of current approved documentation supporting the validated state for the
program addressed.
• Execution plan for the specific validation program addressed (based on calendar
year)

Upon approval of the Sub-VMP, annual updates will be issued to describe the current
year’s project plan status. Record of the annual review will be attached to the Sub-VMP.

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7.3 VALIDATION APPROACH

Validation of facilities, equipment, computer systems, and processes is performed at
the Springfield, NY Facility for production, monitoring, control, evaluation, and
storage of CGMP products. As indicated in the INTRODUCTION section, this site
VMP is based on the Validation Life Cycle approaches presented at the site level
through governing document SOP-XXXX. SOP-XXXX focuses extensively on the
early phases of a project (risk assessment, requirement specification, design,
construction, and engineering). The Validation Lifecycle Process Key Activities
shown in Figure 2 depicts the use of risk based approach that drives the verification
and qualification activities, which are within the scope of this VMP.

The Life Cycle Approach may be summarized as follows:

Facility Qualification will entail verifying that construction and utility installation is
according to design, and that the process requirements are met. Equipment &
Instrument Verification will verify and document that installation is according to
design (Installation Qualification), meets functional requirements (Operational
Qualification), and user requirements (Performance Qualification). All computer and
automated control systems employed in the facility will also be validated.

Process demonstration, or engineering runs, for new processes/products will be
executed utilizing the proposed manufacturing processes. The process
demonstration phase will be based on documented process descriptions developed
for the product to be transferred to the Springfield, NY Facility site. To support
process demonstration, the test instruments will be qualified, and test methods will
be validated and / or formally transferred to the site Quality Control / Microbiology
Laboratories. During the demonstration phase, raw material supply, equipment
settings, process parameters, batch record, product storage, standard operating
procedures, and testing will be evaluated to assure satisfactory function. During the
demonstration phase, evaluations specific to processing and product quality may
also be undertaken.

After successful demonstration, confirmatory production performance qualification
and continued verification protocols will be executed to verify and document that the
manufacturing processes are capable of consistently yielding product that meets
predetermined quality attributes when run at prescribed operating settings and within
acceptable operating ranges. Stability testing will also be conducted to support
product expiration dating intervals.

Cleaning validation will be performed for process contact surfaces to assure that the
cleaning operation reduces product and cleaning agent to acceptable levels.

Subsequent to initial validation activities, the facilities, equipment, systems, and
processes are to be maintained in the validated state through implementation of site
procedures, including calibration, preventive maintenance, requalification, work
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order review, and change control. The validated manufacturing processes will be
assessed regularly to assure that it operates within specified critical parameter
ranges and the product produced continues to meet critical quality attribute
specifications. As necessary validation activities can and will be repeated for
facilities, equipment, instruments or processes that have been modified, replaced, or
otherwise altered to a state outside of the originally validated operating parameters.
The validated state of the critical processes, such as cleaning, sterilization, and
storage rooms, will be requalified periodically.

NOTES about the Validation Life Cycle Process:
• The activities in this process are executed by a cross functional team, which
include Subject Matter Experts (SMEs) from the impacted stakeholder
departments. The responsibilities of SMEs from various functional areas are
listed in Section 4.0 of this VMP.
• The order of activities in the Life Cycle Process follows the sequence shown in
Figure 2.
• The requirement documents (user, functional, regulatory, etc) are generated by
contributions from stakeholder groups.
• Risk assessment is conducted to identify Critical Aspects (CA) of the equipment
and processes.
• Relevant documents are generated and executed per the Verification Plan, such
as FAT, SAT, commissioning, IQ, OQ, and approved prior to starting the next
activity.
• Content of the verification protocols will depend upon the risk assessment as
delineated in the Verification Plan.

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The procedures that follow are part of the infrastructure for the validation process and are a
harmonization of these approaches supplemented by direction to specific Standards and SOPs,
when appropriate.

7.4 VALIDATION PROCEDURES

Validation activities occur for new or modified equipment, systems, utilities, software,
processes or routinely for the re-qualification of equipment, systems or processes
per VP-XXXX, Validation Program for Springfield Manufacturing Operations.
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Prospective validation is required for all new facilities, equipment, systems, utilities,
software, or processes that are necessary for the manufacture, testing, and
storage/distribution of commercial product and for clinical material. The steps
followed for a validation project are referred to as the Validation Life Cycle.
Concurrent validation can be used for PV if the manufactured product must be used
for commercial needs in which case, the PV test results must meet all of acceptance
criteria defined in the protocol as well as any other QA, corporate, and regulatory
requirements. For concurrent validation, the details of the conditions that have to be
met prior to the release of the batch for commercial use must be included in the PV
protocol.

The verification (commissioning, IQ, OQ, etc), PQ, and PV protocols are generated
and executed per the SOPs XXXX. The verification / qualification / validation results
are summarized in corresponding final reports.

The final reports are written in accordance with procedure SOP-XXXX and are
reviewed and approved by the same departments that reviewed and approved the
initial protocol.

7.5 VALIDATION SUPPORT SYSTEMS

7.5.1 Re-Qualification Program

The Re-Qualification (RQ) process is governed by SOP-XXXX. The purpose of
this standard is to provide the mandatory compliance requirements for the
routine requalification practices to be utilized for equipment and processes
used in the manufacture of commercial and clinical material. The intent of
requalification is to ensure critical equipment and processes continue to
perform within defined limits and operate in a similar manner as originally
validated. This document is intended to provide direction to all applicable
Pharma Co., Inc. sites to ensure validation requalification programs comply
with current regulations and guidance documents authored by regulatory
agencies and industry organizations worldwide.

Detailed re-qualification requirements for equipment, systems and processes
at Pharma Co., Inc. facilities, which include the Springfield, NY Facility, are
governed by SOP-XXXX. This procedure is intended to define the time-based
re-qualification program for equipment, systems, and processes at Pharma
Co., Inc. facilities. Specifically, the procedure will identify the equipment,
systems and processes requiring routine re-qualification, the required
frequency and the type of testing and documentation required.

In addition, the Steam-in-Place requalification schedule at Pharma Co., Inc.’s
Springfield, NY Facility is governed by SOP-XXXX. This requalification plan
identifies the equipment / systems group into families requiring Steam-in-Place
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sterilization procedures as part of a validated process. This requalification
plan also specifies and justifies the requalification frequency of the family
group and the family group members. The validated family groups then
require requalification according to SOP-XXXX.

The re-qualification program assures that critical equipment, systems, and
processes continue to perform within prescribed limits and are operating in a
similar manner as originally validated, thereby demonstrating a continued state
of control.

The re-qualification approach is to perform similar testing utilized during the
initial validation, however at an attenuated level deemed sufficient to evaluate
the performance of the equipment, system or process, and detect potential
adverse changes.

7.5.2 Metrology Program

Calibration policies and procedures are governed by SOP-XXXX, Metrology
Program. The Metrology Program covers the services provided by the
Pharma Co., Inc. Metrology Department to Pharma Co., Inc. Corporation. This
includes, but is not limited to, all Manufacturing and Quality Control operations
at Pharma Co., Inc.’s Springfield, NY Facility. Services by the Pharma Co.,
Inc. Metrology Department may also be provided to Pharma Co., Inc.’s
subsidiaries and to joint projects involving other companies having
partnerships with Pharma Co., Inc. and its subsidiaries.

In order for equipment to be included in this program, it must be used to
measure, gauge, test, inspect or otherwise examine a quantitative value to a
known degree of accuracy. If such equipment is used, it must be identified as
a Critical, Non-Critical, or Reference Use Only instrument.

Instrumentation requiring calibration must be current prior to and remain
current during protocol execution and throughout the Validation Program.

7.5.3 Change Control Program

The Corporate Quality Operations Standard for Change Control is documented
as SOP-XXXX. The Change Control Program to ensure that equipment within
the Springfield, NY Facility maintains its validated state is governed by SOP-
XXXX.

These program requirements apply to all Pharma Co., Inc. functional groups
involved in the manufacture and testing of products (both commercial and
clinical including material/ assays used to demonstrate product comparability)
at the Springfield, NY Facility.

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New equipment, both within Quality Control and Manufacturing intended to be
validated, is covered under this Change Control System.

7.5.4 Maintenance Program

The process used for developing and optimizing an effective asset
maintenance program is governed by SOP-XXXX, Springfield, NY Facility
Maintenance Management Program / Work Order System Procedure. The
procedure applies to new and in-service assets based on risks and operational
reliability while assuring employee safety. The process calls for utilizing
operational and maintenance experience relative to 21 CFR Part 210/211 and
quality management systems that must be compliant with CGMP regulations.
The process to determine / evaluate Part 11 compliance and security risks is
included.

The maintenance program targets critical production equipment, QC
Laboratory equipment and test instrumentation, plant utilities and
environmental areas with significant risk to product quality. Process steps for
developing / optimizing the maintenance program are described in the
program. Additionally, instructions for work order management and integration
with the Computerized Maintenance Management System (CMMS) are also
described.

7.5.5 Training Program
The general definitions, responsibilities, methodologies for assignments,
assessments, documentation of training, and integration with the LMS is
governed by SOP-XXXX Learning Management System. This document
outlines the activities required to document training in compliance with CGMPs
and other applicable regulatory requirements and ensures personnel
performing work affecting product quality will be competent on the basis of
appropriate education, training, and experience.

This document applies to the recording of training for full-time, part-time and
non-employees (temporary/contractors) and either concurrent or subsequent
entry of records into the LMS database, where applicable. If a Business Unit
has its own local training procedures, that procedure may take precedence.

Training is further defined in SOP-XXXX, to establish a set of initial, minimal
regulatory training requirements for personnel having the ability to impact
medical device or therapeutic product quality. This document applies to all
full-time, part-time, and temporary employees at all levels whose tasks affect
the design, production, testing, handling and distribution of products, or affect
the environment, process or systems in which products or data are produced,
controlled or managed.

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7.6 KEY SOPs GOVERNING AND SUPPORTING THE ALLSTON LANDING
VALIDATION PROGRAM

See Attachment B for a full list of key SOPs and standards used to support the
Springfield, NY Facility Validation Program. The site SOPs are written, revised, and
controlled per SOP-XXXX, Documentation System and Control.

7.7 IDENTIFICATION AND DESCRIPTION OF MANUFACTURING SYSTEMS AND
EQUIPMENT PRESENTLY IN USE AT THE SPRINGFIELD, NY FACILITY AND
ASSOCIATED COMPLETED VALIDATION

See Attachment C for a Process Equipment List and Associated Validation Protocol
Numbers.

7.8 VALIDATION MASTER PLAN REVIEW

This document must be reviewed, updated and approved on an annual basis to
reflect current philosophy, standards and Good Manufacturing Practices. A “VMP
Review Schedule” must be generated for the time of the year, when the Site VMP
and sub-VMPs will be reviewed and a VMP Review Summary Report generated.

8.0 ATTACHMENTS

8.1 Attachment A: Process Flow Diagrams
8.2 Attachment B: Key SOPs Governing and Supporting the Springfield, NY Facility
Validation Program
8.3 Attachment C: Process Equipment List and Associated Validation Protocol Numbers

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8.1 Attachment A: Product Process Flow Diagrams

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8.2 Attachment B: Key Documents Governing and Supporting the Springfield, NY Facility
Validation Program

Reference Documents
• Food and Drug Administration (FDA) – 21 CFR Parts 11, 210 & 211
• European Medicines Agency (EMA) – EudraLex Vol 4
• International Committee on Harmonization (ICH) – Q7, Q8, Q9 & Q10
• International Standards Organization (ISO) - ISO 9001
• FDA Guidance for Industry – Quality Systems Approach to Pharmaceutical
cGMP Regulations
• FDA Guidance for Industry – Process Validation: General Principles and
Practices – January 2011
• ASTM International – Designation E2500-07, Standard Guide for the
Specification, Design, and Verification of Pharmaceutical and
Biopharmaceutical Manufacturing Systems and Equipment

Corporate Standards:
• SOP-XXXX: Change Control
• SOP-XXXX: Quality Manual for the Pharma Co., Inc. Quality System
• SOP-XXXX: Corporate Quality Operations Standard: Risk Management
• SOP-XXXX: Corporate Quality Operations Standard for Equipment and
Process Requalification
• SOP-XXXX: Method Development and Validation
• SOP-XXXX: Validation Program
• SOP-XXXX: Laboratory Equipment Qualification
• SOP-XXXX: Cleaning Validation
• SOP-XXXX: Process Validation
• SOP-XXXX: Sterilization and Depyrogenation Validation

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General and Administrative SOPs:

• SOP-XXXX: Documentation System and Control
• SOP-XXXX: Generation of Protocols and Final Reports for Validation
• SOP-XXXX: Change Control Procedure
• SOP-XXXX: Metrology Program
• SOP-XXXX: Records Retention
• SOP-XXXX: Springfield, NY Facility Maintenance Management Program /
Work Order System Procedure
• SOP-XXXX: Technology Transfer into TMD Manufacturing and Quality
• SOP-XXXX: Guidance for 21 CFR Part 11 Compliance for
TMD Computer Systems
• SOP-XXXX: Pharma Co., Inc. Corporate Quality Manual
Note: This manual also lists pertinent SOPs for validation
related topics
• SOP-XXXX: Documentation of Employee Training
• SOP-XXXX: Installation Qualification of Laboratory Instruments
• SOP-XXXX: Learning Management System (LMS)– Governance and
Documentation
• SOP-XXXX: cGMP & Regulatory Training Requirements for Personnel

Engineering SOPs:
• SOP-XXXX: Technical Project Management Process for Springfield, NY
Facility Manufacturing Facility
• SOP-XXXX: Project Lifecycle Management Process - Springfield, NY
Facility
• SOP-XXXX: Commissioning Procedure for Start-Up of Systems and
Equipment at Springfield, NY Facility
• SOP-XXXX: Engineering Document Management Procedure at the
• SOP-XXXX: Administration of Drawings at Pharma Co., Inc. Springfield, NY
Facility
• SOP-XXXX: Project Change Management Procedure at the Springfield, NY
Facility

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Technical SOPs:
• SOP-XXXX: Validation of Autoclaves
• SOP-XXXX: Validation of Dry Heat Ovens used in Sterilization or
Depyrogenation Processes
• SOP-XXXX: Validation of Filter Integrity Test Instruments
• SOP-XXXX: Validation of Temperature/Relative Humidity Controlled Warm
Rooms/Chambers

Key Validation Department Operational SOPs:
• SOP-XXXX: Master Validation Plan for the Pharma Co., Inc. Laboratory
Information Management System
• SOP-XXXX: Standard Operating Procedure Guidelines for Determination of
Validation Requirements for Change Control Requests
• SOP-XXXX: Guidelines for Computer Validation Protocols
• SOP-XXXX: Guidelines for Generating, Approving, Amending and Closing-
out a Validation Plan at Pharma Co., Inc.
• SOP-XXXX: Guidelines for the Performance of Airflow Pattern Testing for
Clean Rooms and Laminar Flow Hoods
• SOP-XXXX: Protocol Execution Procedure at Springfield, NY Facility
• SOP-XXXX: Routine Re-Qualification of Equipment, Systems and Processes
• SOP-XXXX: Cleaning Validation and Changeover Verification
• SOP-XXXX: Process Validation for Springfield, NY Facility
• SOP-XXXX: Process Equipment Steam-in-Place (SIP) Requalification
Matrices and Scheduling Plan at Springfield, NY Facility
• SOP-XXXX: Cleaning Master Plan for the Springfield, NY Facility
Manufacturing Facility
• SOP-XXXX: Validation Project Execution Life Cycle Approach at the

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8.3 Attachment C: Process Equipment List and Associated Validation Protocol
Numbers

EQ # Description Size Location IQ OQ CIP SIP CQ PQ/PV

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9.0 REVISION HISTORY

9.1 Revision History Table

Revision Description of Changes DCR Related Date
Number document
1 Initial Release xxxx xxxx mm/dd/yyyy

NOTICE

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